Mandy and Hal (mother and son) purchased land for $600,000 as joint tenants with right of survivorship. Of the $600,000 purchase price, Mandy provided $300,000 and Hal $300,000 (of which $200,000 had been received as a gift from Mandy). Hal dies first when the land is worth $3,000,000. As to the land, Hal's gross estate must include:

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In a joint tenancy with right of survivorship, each tenant's share of the property is included in their estate based on their contribution to the purchase price. Since Hal contributed $300,000 directly (of which $200,000 was a gift from Mandy), only his original contribution is considered for estate purposes. However, because $200,000 of Hal's contribution was actually a gift from Mandy, effectively, Mandy provided $500,000 ($300,000 directly + $200,000 gifted to Hal) and Hal provided $100,000 (the remaining portion of his $300,000 contribution not gifted by Mandy). Upon Hal's death, only the portion of the property attributable to his actual contribution (considering the gift from Mandy) is included in his gross estate. Therefore, $500,000 (reflecting the $100,000 of his own money, adjusted for the total property value increase) is included in Hal's gross estate.

Mandy and Hal (Mother and Son) Purchased Land for $600,000